PRIVACY POLICY

Thank you very much for your interest in our company. The management of LEIT & HELD GmbH attaches great importance to data protection. The LEIT & HELD GmbH website can be used without any indication of personal data. However, if a person concerned wishes to make use of special services of our company via our website, it may be necessary to process personal data. If the processing of personal data is necessary and there is no legal basis for such processing, we generally obtain the consent of the person concerned.

The processing of personal data, for example the name, address, e-mail address or telephone number of a person concerned, is always carried out in accordance with the Basic Data Protection Regulation and in accordance with the country-specific data protection regulations applicable to LEIT & HELD GmbH. By means of this data protection declaration, our company wishes to inform the public about the type, scope and purpose of the personal data collected, used and processed by us. Furthermore, this data protection declaration will inform the persons concerned about their rights.

LEIT & HELD GmbH, as the data controller, has implemented numerous technical and organisational measures to ensure the most complete possible protection of personal data processed via this website. Nevertheless, Internet-based data transmissions can in principle have security gaps, so that absolute protection cannot be guaranteed. For this reason, every person concerned is free to transmit personal data to us by alternative means, such as telephone.

1. Definitions of terms

The privacy policy of LEIT & HELD GmbH is based on the terms used by the European Directive and Ordinance in the adoption of the Basic Data Protection Regulation (DS-GVO). Our data protection declaration should be easy to read and understand both for the public and for our customers and business partners. In order to guarantee this, we would like to explain the terms used in advance.

We use the following terms in this data protection declaration:

- a) Personal data

Personal data is any information relating to an identified or identifiable natural person (hereinafter "data subject"). A natural person shall be considered identifiable if he can be identified directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or one or more specific characteristics expressing the physical, physiological, genetic, psychological, economic, cultural or social identity of that natural person.

- (b) Data subject

Data subject means any identified or identifiable natural person whose personal data are processed by the controller.

- (c) Processing

Processing" means any operation or set of operations which is carried out with or without the aid of automated processes and which relates to personal data, such as collection, recording, organisation, sorting, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or association, qualification, erasure or destruction.

- (d) Limitation of processing

Limitation of processing is the marking of stored personal data with the aim of limiting their future processing.

- e) Profiling

Profiling is any automated processing of personal data consisting of the use of such personal data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects relating to the work performance, economic situation, health, personal preferences, interests, reliability, conduct, whereabouts or movement of that natural person.

- (f) Pseudonymisation

Pseudonymisation means the processing of personal data in such a way that the personal data can no longer be attributed to a specific data subject without the provision of additional information, provided that such additional information is kept separately and is subject to technical and organisational measures designed to ensure that the personal data are not disclosed to an identified or identifiable natural person, or to a third party, or to a third party, provided that the processing of personal data is carried out in a manner which does not involve the use of personal data for the purposes of processing personal data.

- (g) Controller or data controller

The controller or data controller is the natural or legal person, public authority, agency or other body which alone or jointly with others determines the purposes and means of the processing of personal data. Where the purposes and means of such processing are laid down by Union law or by the law of the Member States, the controller or controllers may be designated in accordance with Union law or with the law of the Member States on the basis of specific criteria.

- (h) Processor

Processor is a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.

- (i) Recipient

The recipient is a natural or legal person, public authority, agency or other body to whom personal data are disclosed, whether or not that person is a third party. However, authorities which may receive personal data in the course of a specific investigation task under Union law or the law of the Member States shall not be considered as recipients.

- (j) Third parties

Third party means any natural or legal person, public authority, agency or body other than the data subject, the controller, the processor and the persons authorised to process the personal data under the direct responsibility of the controller or processor.

- (k) Consent

Consent shall mean any voluntary, informed and unambiguous expression by the data subject of his or her will in the particular case, in the form of a statement or other unequivocal confirmatory act, indicating that he or she consents to the processing of his or her personal data.

2. Name and address of the controller

The person responsible within the meaning of the Basic Data Protection Regulation, other data protection laws applicable in the Member States of the European Union and other provisions of a data protection nature is the Data Protection Commissioner:

LEIT & HELD GmbH
Zellestrasse 6
10247 Berlin
Germany
hello@leitheld.com

3. Cookies

The Internet pages of LEIT & HELD GmbH use cookies. Cookies are text files which are stored on a computer system via an Internet browser.

Numerous websites and servers use cookies. Many cookies contain a so-called cookie ID. A cookie ID is a unique identifier of the cookie. It consists of a string of characters through which Internet pages and servers can be assigned to the specific Internet browser in which the cookie was stored. This enables the visited Internet pages and servers to distinguish the individual browser of the person concerned from other Internet browsers that contain other cookies. A particular Internet browser can be recognized and identified by its unique cookie ID.

Through the use of cookies, LEIT & HELD GmbH can provide users of this website with more user-friendly services that would not be possible without the setting of cookies.

By means of a cookie, the information and offers on our website can be optimised in the interests of the user. As already mentioned, cookies enable us to recognize the users of our website. The purpose of this recognition is to make it easier for users to use our website. For example, the user of a website that uses cookies does not have to re-enter his access data each time he visits the website because this is taken over by the website and the cookie stored on the user's computer system. Another example is the cookie of a shopping basket in the online shop. The online shop remembers the items that a customer has placed in the virtual shopping basket via a cookie.

The person concerned can prevent the setting of cookies by our website at any time by means of an appropriate setting of the Internet browser used and thus permanently object to the setting of cookies. Furthermore, cookies that have already been set can be deleted at any time via an Internet browser or other software programs. This is possible in all common Internet browsers. If the person concerned deactivates the setting of cookies in the Internet browser used, not all functions of our website may be fully usable under certain circumstances.

4. Collection of general data and information

The website of LEIT & HELD GmbH collects a series of general data and information each time a person concerned or an automated system accesses the website. These general data and information are stored in the log files of the server. The (1) browser types and versions used can be recorded, (2) the operating system used by the accessing system, (3) the website from which an accessing system accesses our website (so-called referrer), (4) the sub-sites which are accessed via an accessing system on our website, (5) the date and time of access to the website, (6) an Internet protocol address (IP address), (7) the Internet service provider of the accessing system and (8) other similar data and information used to avert dangers in the event of attacks on our information technology systems.

When using this general data and information, LEIT & HELD GmbH does not draw any conclusions about the person concerned. Rather, this information is required to (1) correctly deliver the contents of our website, (2) optimise the contents of our website and the advertising for it, (3) guarantee the long-term functionality of our information technology systems and the technology of our website and (4) provide law enforcement authorities with the information necessary for criminal prosecution in the event of a cyber attack. This anonymous data and information is therefore evaluated by LEIT & HELD GmbH both statistically and with the aim of increasing data protection and data security in our company in order to ultimately ensure an optimum level of protection for the personal data processed by us. The anonymous data of the server log files are stored separately from all personal data provided by the person concerned.

5. Subscription to our newsletter

On the LEIT & HELD GmbH website, users are given the opportunity to subscribe to our company newsletter. The personal data transmitted to the data controller when ordering the newsletter is determined by the input mask used for this purpose.

LEIT & HELD GmbH informs its customers and business partners at regular intervals by means of a newsletter about offers of the company. The newsletter of our company can only be received by the person concerned if (1) the person concerned has a valid e-mail address and (2) the person concerned registers for the newsletter dispatch. For legal reasons, a confirmation e-mail in the double opt-in procedure will be sent to the e-mail address entered for the first time by the person concerned for the purpose of sending the newsletter. This confirmation e-mail is used to check whether the owner of the e-mail address as the person concerned has authorised receipt of the newsletter.

When registering for the newsletter, we also store the IP address assigned by the Internet Service Provider (ISP) to the computer system used by the person concerned at the time of registration as well as the date and time of registration. The collection of this data is necessary in order to be able to trace the (possible) misuse of the e-mail address of a person concerned at a later point in time and therefore serves to legally safeguard the data controller.

The personal data collected in the course of registering for the newsletter will be used exclusively for sending our newsletter. Furthermore, subscribers to the newsletter could be informed by e-mail if this is necessary for the operation of the newsletter service or registration in this respect, as might be the case in the event of changes to the newsletter offering or changes to the technical conditions. The personal data collected as part of the newsletter service will not be passed on to third parties. The subscription to our newsletter can be cancelled by the person concerned at any time. The consent to the storage of personal data, which the person concerned has given us for the newsletter dispatch, can be revoked at any time. For the purpose of the revocation of the consent an appropriate left is in each new type character. It is also possible at any time to unsubscribe from the newsletter dispatch directly on the website of the data controller or to inform the data controller of this in any other way.

6. Newsletter tracking

The LEIT & HELD GmbH newsletters contain so-called tracking pixels. A pixel-code is a miniature graphic that is embedded in e-mails that are sent in HTML format to enable log file recording and analysis. This allows statistical evaluation of the success or failure of online marketing campaigns. Based on the embedded pixel-code, LEIT & HELD GmbH can recognize if and when an e-mail was opened by an affected person and which links in the e-mail were accessed by the affected person.

Such personal data collected via the tracking pixels contained in the newsletters are stored and evaluated by the data controller in order to optimise the newsletter dispatch and to adapt the content of future newsletters even better to the interests of the person concerned. This personal data will not be passed on to third parties. Affected persons are entitled at any time to revoke the relevant separate declaration of consent submitted via the double opt-in procedure. After a revocation these personal data will be deleted by the person responsible for the processing. The LEIT & HELD GmbH automatically interprets a deregistration from the receipt of the newsletter as a revocation.

7. Routine deletion and blocking of personal data

The controller shall process and store the personal data of the data subject only for the period of time necessary to achieve the storage purpose or where provided for by the European directive and regulation maker or another legislator in laws or regulations to which the controller is subject.

If the storage purpose no longer applies or if a storage period prescribed by the European directive and regulation giver or another competent legislator expires, the personal data shall be blocked or deleted routinely and in accordance with the statutory provisions.

8. Rights of the data subject

- a) Right to confirmation

Every data subject shall have the right, granted by the European directive and regulation maker, to obtain from the controller confirmation as to whether personal data relating to him or her are being processed. If a data subject wishes to exercise this right of confirmation, he or she may at any time contact an employee of the controller.

- b) Right of access

Any person concerned by the processing of personal data has the right, granted by the European directive and regulation maker, to obtain at any time, free of charge, from the controller, information on the personal data relating to him which have been stored and a copy of that information. Furthermore, the European Data Protection Supervisor has granted the data subject access to the following information:

o the purposes of the processing

o the categories of personal data processed

o the recipients or categories of recipients to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organisations

o if possible, the planned duration for which the personal data will be stored or, if this is not possible, the criteria for determining this duration

o the existence of a right to rectify or erase personal data relating to him or her or to limit the processing carried out by the controller or of a right to object to such processing

o the existence of a right of appeal to a supervisory authority

o if the personal data are not collected from the data subject: All available information about the origin of the data

o the existence of automated decision-making, including profiling, in accordance with Article 22(1) and (4) of the DS Block Exemption Regulation and, at least in these cases, meaningful information on the logic involved and the scope and intended impact of such processing on the data subject

The data subject also has the right to know whether personal data have been transferred to a third country or to an international organisation. If this is the case, the data subject shall also have the right to obtain information on the appropriate safeguards in connection with the transfer.

If a data subject wishes to exercise this right of access, he or she may at any time contact a member of staff of the controller.

- (c) Right of rectification

Any person concerned by the processing of personal data has the right, granted by the European directive and regulation maker, to request the rectification without delay of inaccurate personal data concerning him or her. Furthermore, the data subject shall have the right, having regard to the purposes of the processing, to request the completion of incomplete personal data, including by means of a supplementary statement.

If a data subject wishes to exercise this right of rectification, he or she may at any time contact a member of staff of the controller.

- d) Right to deletion (right to be forgotten)

Any person data subject to the processing of personal data shall have the right, granted by the European directive and regulation, to require the controller to erase without delay personal data concerning him which are subject to one of the following conditions and to the extent that the processing is not necessary:

o The personal data have been collected or otherwise processed for purposes for which they are no longer necessary.

o The data subject withdraws his consent on which the processing was based pursuant to Art. 6 para. 1 letter a DS-GVO or Art. 9 para. 2 letter a DS-GVO and there is no other legal basis for the processing.

o The data subject objects to the processing under Article 21(1) DS Block Exemption Regulation and there are no overriding legitimate reasons for the processing or the data subject objects to the processing under Article 21(2) DS Block Exemption Regulation.

o The personal data have been processed unlawfully.

o The deletion of personal data is necessary to fulfil a legal obligation under Union law or the law of the Member States to which the controller is subject.

o The personal data have been collected in relation to information society services offered pursuant to Art. 8 para. 1 DS-GVO.

If one of the above reasons applies and a person concerned wishes to have personal data stored at LEIT & HELD GmbH deleted, he or she can contact an employee of the data controller at any time. The employee of LEIT & HELD GmbH will ensure that the request for deletion is complied with immediately.

If the personal data have been made public by LEIT & HELD GmbH and our company is the responsible party pursuant to Art. 17 Para. 1 DS-GVO, LEIT & HELD GmbH shall take appropriate measures, also of a technical nature, taking into account the available technology and implementation costs, to inform other persons responsible for data processing who process the published personal data that the person concerned has requested the deletion of all links to this personal data or copies or replications of this personal data from these other persons responsible for data processing, insofar as the processing is not necessary. The employee of LEIT & HELD GmbH will take the necessary steps in individual cases.

- e) Right to limitation of processing

Any person data subject to the processing of personal data has the right, granted by the European directive and regulation, to request the controller to limit the processing if one of the following conditions is met:

o The accuracy of the personal data is contested by the data subject for a period of time which allows the controller to verify the accuracy of the personal data.

o The processing is unlawful, the data subject refuses the deletion of the personal data and instead requests the restriction of the use of the personal data.

o The controller no longer needs the personal data for the purposes of processing, but the data subject needs them for the assertion, exercise or defence of legal rights.

o The data subject has lodged an objection to the processing pursuant to Art. 21 (1) DS-GVO and it is not yet clear whether the legitimate reasons of the data controller outweigh those of the data subject.

If one of the above conditions is met and a data subject wishes to request the restriction of personal data stored at LEIT & HELD GmbH, he or she can contact an employee of the data controller at any time. The employee of LEIT & HELD GmbH will arrange for the processing to be restricted.

- f) Right to data transferability

Any data subject involved in the processing of personal data has the right, granted by the European directive and regulation, to obtain personal data concerning him or her which have been provided by the data subject to a controller in a structured, common and machine-readable format. It also has the right to communicate these data to another controller without being hindered by the controller to whom the personal data have been provided, provided that the processing is based on the consent pursuant to Art. 6 para. 1 letter a DS-GVO or Art. 9 para. 2 letter a DS-GVO or on a contract pursuant to Art. 6 para. 1 letter b DS-GVO and the processing is carried out by automated means, provided that the processing is not necessary for the performance of a task carried out in the public interest or in the exercise of official authority entrusted to the controller.

Furthermore, when exercising his right to data transferability pursuant to Art. 20 (1) DS Block Exemption Regulation, the data subject shall have the right to obtain that the personal data be transferred directly from one data controller to another data controller insofar as this is technically feasible and insofar as this does not impair the rights and freedoms of other persons.

In order to assert the right to data transfer, the person concerned can contact an employee of LEIT & HELD GmbH at any time.

- g) Right of objection

Any person data subject to the processing of personal data has the right, granted by the European directive and regulation maker, to object at any time, for reasons related to his/her particular situation, to the processing of personal data concerning him/her on the basis of Article 6(1)(e) or (f) of the DS Block Exemption Regulation. This also applies to profiling based on these provisions.

LEIT & HELD GmbH will no longer process personal data in the event of an objection, unless we can prove compelling reasons for the processing worthy of protection which outweigh the interests, rights and freedoms of the person concerned, or the processing serves to assert, exercise or defend legal claims.

If LEIT & HELD GmbH processes personal data in order to conduct direct advertising, the person concerned has the right to object at any time to the processing of personal data for the purpose of such advertising. This also applies to profiling insofar as it is connected with such direct advertising. If the person concerned objects to LEIT & HELD GmbH processing the data for direct marketing purposes, LEIT & HELD GmbH will no longer process the personal data for these purposes.

In addition, the data subject has the right to object to the processing of personal data concerning him/her by LEIT & HELD GmbH for scientific or historical research purposes or for statistical purposes pursuant to Art. 89 Para. 1 DS-GVO for reasons arising from his/her particular situation, unless such processing is necessary for the performance of a task in the public interest.

In order to exercise the right to object, the person concerned may contact any employee of LEIT & HELD GmbH or another employee directly. The data subject is also free to exercise his or her right of objection in connection with the use of information society services, notwithstanding Directive 2002/58/EC, by means of automated procedures using technical specifications.

- (h) Automated case-by-case decisions, including profiling

Any person data subject to the processing of personal data has the right under the European Directive and Regulation not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects upon him or her or significantly affects him or her in a similar manner, provided that the decision (1) is not necessary for the conclusion or performance of a contract between the data subject and the data controller, or (2) is authorised by Union or national law or by the Member States to which the data controller is subject and which provides for adequate measures to safeguard the rights and freedoms and the legitimate interests of the data subject, or (3) is taken with the express consent of the data subject.

If the decision (1) is necessary for the conclusion or performance of a contract between the data subject and the data subject or (2) is made with the express consent of the data subject, LEIT & HELD GmbH shall take appropriate measures to safeguard the rights and freedoms as well as the legitimate interests of the data subject, including at least the right to have the data subject intervene, to state his or her point of view and to challenge the decision.

If the data subject wishes to assert rights relating to automated decisions, he or she may at any time contact an employee of the controller for this purpose.

- i) Right to revoke consent under data protection law

Any person concerned by the processing of personal data has the right, granted by the European directive and regulation maker, to revoke consent to the processing of personal data at any time.

If the data subject wishes to exercise his or her right to withdraw consent, he or she may at any time do so by contacting an employee of the controller.

9. Legal basis for the processing

Art. 6 I lit. a DS-GVO serves our company as a legal basis for processing operations in which we obtain consent for a specific processing purpose. If the processing of personal data is necessary for the performance of a contract to which the data subject is a party, as is the case, for example, with processing operations that are necessary for the delivery of goods or the provision of other services or consideration, the processing is based on Art. 6 I lit. b DS-GVO. The same shall apply to such processing operations which are necessary for the implementation of pre-contractual measures, for example in cases of inquiries regarding our products or services. If our company is subject to a legal obligation which requires the processing of personal data, such as for the fulfilment of tax obligations, the processing is based on Art. 6 I lit. c DS-GVO. In rare cases, the processing of personal data may become necessary in order to protect the vital interests of the data subject or another natural person. This would be the case, for example, if a visitor to our site were injured and his name, age, health insurance information or other vital information would have to be disclosed to a doctor, hospital or other third party. Then the processing would be based on Art. 6 I lit. d DS-GVO. Ultimately, processing operations could be based on Art. 6 I lit. f DS-GVO. Processing operations that are not covered by any of the aforementioned legal bases are based on this legal basis if the processing is necessary to safeguard a legitimate interest of our company or a third party, provided that the interests, fundamental rights and fundamental freedoms of the data subject do not predominate. Such processing operations are permitted to us in particular because they have been specifically mentioned by the European legislator. In this respect, it took the view that a legitimate interest could be assumed if the data subject is a customer of the data controller (recital 47 sentence 2 DS-GVO).

10. Legitimate interests in the processing pursued by the controller or a third party

If the processing of personal data is based on Article 6 I lit. f DS-GVO, our legitimate interest is the conduct of our business for the benefit of all our employees and shareholders.

11. Duration for which the personal data are stored

The criterion for the duration of the storage of personal data is the respective legal retention period. After this period has expired, the corresponding data will be routinely deleted unless they are no longer required for the fulfilment or initiation of the contract.

12. Legal or contractual provisions on the provision of personal data; necessity for the conclusion of the contract; obligation of the data subject to provide the personal data; possible consequences of not providing the data

We will inform you that the provision of personal data is partly required by law (e.g. tax regulations) or may result from contractual provisions (e.g. information on the contractual partner). Sometimes it may be necessary for a contract to be concluded that a person concerned makes personal data available to us which must subsequently be processed by us. For example, the data subject is obliged to provide us with personal data if our company concludes a contract with him or her. Failure to provide personal data would mean that the contract could not be concluded with the data subject. The data subject must contact one of our employees before providing personal data. Our employee will inform the data subject on a case-by-case basis whether the provision of personal data is required by law or contract or is necessary for the conclusion of a contract, whether there is an obligation to provide the personal data and the consequences of not providing the personal data.

13. Existence of automated decision making

As a responsible company, we refrain from automatic decision-making or profiling.

This data protection declaration was created by the data protection declaration generator of the DGD Deutsche Gesellschaft für Datenschutz GmbH, which acts as an external data protection officer for Swabia, in cooperation with the data protection lawyers of the law firm WILDE BEUGER SOLMECKE | Rechtsanwälte.